Privacy Policy

Online Privacy Policy

EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC

Introduction

“EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” and its subsidiaries ("”EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC”" "we," or "us") owns and operates websites (the "www.em-bodhi.com") located at “WWW.EM-BODHI.COM” and WWW.EM-BODHI.CO and may have previously, now or in the future own and/or operate a “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” mobile application (collectively, the " Platform"). Your access and use of the Platform any part thereof, or anything associated therewith, including its content ("Content"), any

products or services provided through the Platform or otherwise by “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC”, and any affiliated website, software or application owned or operated by “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” (collectively, including the Platform and the Content, the "Service") are subject to this Privacy

Policy unless specifically stated otherwise. Capitalized terms not otherwise defined in this

Privacy Policy have the same meaning as set forth in the “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” Terms and Conditions ("Terms and Conditions").

We are committed to respecting the privacy of users of the Service. We created this Privacy

Policy ("Privacy Policy") to tell you how “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” collects, uses and discloses information in order to provide you with the Service.

As with our Terms and Conditions, by creating, registering, or logging into an account through

the Service, or otherwise accessing or using the Service, you are automatically accepting and

acknowledging the most recent version of this Privacy Policy. If we make any changes to our

Privacy Policy, we will post the revised Privacy Policy and update the "Last updated" date of the

Privacy Policy.

If you are using the Service on behalf of an individual other than yourself, you represent that you

are authorized by such an individual to act on such an individual's behalf and that such

individual acknowledges the practices and policies outlined in this Privacy Policy.

Limitations on Use by Minors

Our Service is generally intended for use by individuals who are at least eighteen (18) years of

age or such older age as may be required by applicable state laws in the jurisdiction in which an

individual utilizes the Service. Individuals who are between the ages of thirteen (13) and

eighteen (18) (or such older age of majority) may use the Service for the sole purpose of

obtaining a medical consultation for the treatment of acne using topical skincare products (to the

extent made available) if a parent or legal guardian provides consent to such use in accordance

with the requirements set forth in our Terms and Conditions and the Service. The Service is not

designed or intended to attract, and is not directed to, children under thirteen (13) years of age.

If we obtain actual knowledge that we have collected personal information through the Platform

from a person under thirteen (13) years of age, we will use reasonable efforts to refrain from

further using such personal information or maintaining it in retrievable form.

Furthermore, if you are under sixteen (16) years of age, then you (or your parent or legal

guardian if you are under age 13) may at any time request that we remove content or

information about you that is posted on the Platform. Please submit any such request ("Request

for Removal of Minor Information") to either of the following:

By mail: “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC

” Attn: “Aimee Talbott”, “7901 4th St. N. #19005, St. Petersburg, FL 33702”, with a subject line

of "Removal of Minor Information. If you send by mail, please send by U.S. Certified Mail,

Return Receipt Requested to allow for confirmation of mailing, delivery and tracking.

By email: “support@em-bodhi.com”, with a subject line of "Removal of Minor Information"

For each Request for Removal of Minor Information, please state "Removal of Minor

Information" in the email or letter subject line, and clearly state the following in the body of the

request:

The nature of your request

The identity of the content or information to be removed

The location of the content or information on the Platform (e.g. by providing the URL)

That the request is related to the "Removal of Minor Information"

Your name, street address, city, state, zip code and email address, and whether you prefer to

receive a response to your request by mail or email.

We will not accept any Request for Removal of Minor Information via telephone or facsimile.

“EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” is not responsible for failing to comply with any Request for Removal of Minor Information that is incomplete, incorrectly labeled or incorrectly sent.

Please note that we are not required to erase or otherwise eliminate, or enable erasure or

elimination of such content or information in certain circumstances, such as, for example, when

an international, federal, state, or local law, rule or regulation requires “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” to maintain the content or information; when “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” maintains the content or information on behalf of your Providers (as defined in our Terms and Conditions) as part of your

electronic medical record; when the content or information is stored on or posted to the Site by a

third party other than you (including any content or information posted by you that was stored,

republished or reposted by the third party); when “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” anonymizes the content or information, so that you cannot be individually identified; when you do not follow the

aforementioned instructions for requesting the removal of the content or information; and when

you have received compensation or other consideration for providing the content or information.

The foregoing is a description of “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” voluntary practices concerning the collection of personal information through the Service from certain minors, and is not intended to

be an admission that “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” is subject to the Children's Online Privacy Protection Act, the Federal Trade Commission's Children's Online Privacy Protection Rule(s), or any

similar international, federal, state, or local laws, rules, or regulations.

Protected Health Information

When you set up an account with “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC”, you are creating a direct customer relationship with “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” that enables you to access and/or utilize the various functions of the Platform and the Service as a user. As part of that relationship, you provide

information to “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC”, including but not limited to, your name, email address, shipping address, phone number and certain transactional information, that we do not consider

to be "protected health information" or "medical information".

However, in using certain components of the Service, you may also provide certain health or

medical information that may be protected under applicable laws. “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” is not a "covered entity" under the Health Insurance Portability and Accountability Act of 1996, Public

Law 104-191, and its related regulations and amendments from time to time (collectively, "

HIPAA"). One or more of the Labs, Pharmacies or Medical Groups (as defined in our Terms and

Conditions) may or may not be a "covered entity" or "business associate" under HIPAA, and

“EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” may in some cases be a "business associate" of a Pharmacy or Medical Group. It is important to note that HIPAA does not necessarily apply to an entity or person

simply because there is health information involved, and HIPAA may not apply to your

transactions or communications with “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC”, the Medical Groups, the Providers, the Labs, or the Pharmacies. To the extent “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” is deemed a "business associate" however, and solely in its role as a business associate, “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC”, may be subject to certain provisions of HIPAA with respect to "protected health information," as defined under HIPAA, that you provide to “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC”, the Medical Group or the Providers ("PHI"). In addition, any medical or health information that you provide that is subject to specific protections under applicable state laws (collectively, with PHI, "Protected Information"), will be

used and disclosed only in accordance with such applicable laws. However, any information that

does not constitute Protected Information under applicable laws may be used or disclosed in

any manner permitted under this Privacy Policy. Protected Information does not include

information that has been de-identified in accordance with applicable laws.

The Medical Groups and Providers have adopted a Notice of Privacy Practices that describes

how they use and disclose Protected Information. By accessing or using any part of the Service,

you are acknowledging receipt of the Notice of Privacy Practices from your Medical Group and

Provider(s).

By accessing or using any part of the Service, you are agreeing that even if HIPAA does apply

to “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC”, the Medical Groups, the Providers, the Labs or the Pharmacies, any information that you submit to “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” that is not intended and used solely for the provision of diagnosis and treatment by the Medical Group and Providers, laboratory services by the Labs or prescription fulfillment by the Pharmacies, is not considered Protected

Information, and will only be subject to our Privacy Policy and any applicable state laws that

govern the privacy and security of such information. For purposes of clarity, information you

provide to “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” in order to register and set up an account on the Platform, including name, username, email address, shipping address and phone number, are not

considered Protected Information.

Collection of Information

We collect any information you provide when you use the Service, including, but not limited to:

Personally identifying information such as your name and contact data such as your e-mail

address, phone number, and billing and physical addresses

Your login and password and other account ("Account") registration details

Demographic data (such as your gender, date of birth and zip code)

Computer, mobile device and/or browser information (e.g., IP address, mobile device ID

information, operating system, connection speed, bandwidth, browser type, referring/exist web

pages, web page requests, cookie information, hardware attributes, software attributes)

Third-party website, network, platform, server and/or application information (e.g., Facebook,

Twitter, Instagram)

Usage activity concerning your interactions with the Service and/or third-party websites,

networks or applications accessed through the Service (e.g., viewing habits, viewing

preferences, viewing history, number of clicks on a page or feature, amount of time spent on a

page or feature, identify of third-party websites, networks, etc.)

Billing, payment and shipping information

Electronic signature

Photographic or video images submitted for identification or non-diagnosis or treatment

purposes, including photographs of your driver’s license or passport

Information about third parties that you refer to us (e.g., name, email, and/or other contact

information, relationship)

Statements or content (e.g., comments, videos, photographs, images) and information about

such statements or content, which you submit or publish on or through the Service or which are

accessed via your public or linked social media pages (e.g., Facebook, Twitter, Instagram)

Any other information you provide when you contact or communicate with us

If you use your mobile device to visit, access or use the Service, then additional categories of

information that we collect may include

Your name associated with your mobile device

Your telephone number associated with your mobile device

Your geolocation

Your mobile device ID information

With your express consent, your contacts and/or contact information (e.g., names, telephone

numbers, physical addresses, email addresses, photos) stored on your mobile device

With your express consent, information about third-party software applications on your mobile

device (including, without limitation, general software apps, downloadable software apps, social

media apps)

We also collect certain medical information on behalf of the Medical Groups and your Providers,

which may include, but is not limited to:

Health and medical data you submit for diagnosis or treatment purposes, including information

in any questionnaires or surveys you complete for these purposes

Previous doctors or other healthcare providers you visited

Date of visit

Images or videos you share for diagnosis or treatment purposes

Communications with Providers

We may also receive information about you from our partners. For example, as part of our

identity verification process, our vendor may send us information they have independently

collected, such as your name, age, and estimated location. Our marketing partners may also

send us information about you, even if you have not visited or registered on our site.

“EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” does not collect or create biometric information about you. To use some of our services, however, we may be required to verify your identity. If you are asked to submit

proof of identity (such as a driver’s license or passport) we may share that and the selfie you

shared with us with our identity verification partner, who may create biometric information about

your face in order to verify that your selfie matches your proof of identity. Biometric information

is not shared with “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” and is deleted by our identity verification partner after completing the identity verification. “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” may receive information extracted from your photos, such as information from your driver’s license and the confidence that there is a

“match” between your two photos. We use this information to help verify your identity.

How Information Is Collected

“EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” might collect personal and non-personal information directly from you when you visit, access or use the Service; when you register with or subscribe to the Service or any

products or services available through the Service; when you "sign in," "log in," or the like to the

Service; when you allow the Service to access, upload, download, import or export content

found on or through, or to otherwise interact with, your computer or mobile device (or any other

device you may use to visit, access or use the Service) or online accounts with third-party

websites, networks, platforms, servers or applications (e.g., your online social media accounts,

your cloud drives and servers, your mobile device service provider); or whenever “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” asks you for such information, such as, for example, when you process a payment

through the Service, or when you answer an online survey or questionnaire. In addition, if you or

a third party sends “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” a comment, message or other communication (such as, by way of example only, email, letter, fax, phone call, or voice message) about you or your

activities on or through the Site and/or the App, then “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” may collect any personal or non-personal information provided therein or therewith.

In addition to the information we collect directly from you, we may also collect certain

information from the Medical Group and/or Providers who provide treatment or other services to

you in connection with our Service. This information may include, but is not limited to,

diagnoses, treatment plans (including prescription details) and notes, and is accessible and

visible through certain components of the Service.

We may also receive information from third parties that pay for your care or provide you with

treatment, laboratory care or prescription medication, which may include, for example, your

prescription history, insurance policy, insurance eligibility and coverage, and laboratory test

results.

We also may receive personal information about you from our service providers who assist us

with identity verification in connection with our Services, which may include information parsed

from your driver’s license or passport, your estimated location, your address and how long you

have lived there, and your contact information.

Finally, “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” might use various tracking, data aggregation and/or data analysis technologies, including, for example, the following:

Cookies, which are small data files (e.g., text files) stored on the browser or device you use to

view a website or message. They may help store user preferences and activity and may allow a

website to recognize a particular browser or device. There are several types of cookies,

including, for example, browser cookies, session cookies, and persistent cookies. Cookies may

record information you access on one page of a website to simplify subsequent interaction with

that website, or to help streamline your transactions on related pages of that website. Most

major browsers are set up so that they will initially accept cookies, but you might be able to

adjust your browser's or device's preferences to issue you an alert when a cookie is

downloaded, or to block, reject, disable, delete or manage the use of some or all cookies on

your browser or device. Cookies can be set by the website owner (i.e., us), or they can be set

by third parties (e.g., Facebook, Google, etc.) Cookies are used to help us speed up your future

activities or to improve your experience by remembering the information that you have already

provided to us. Third party cookies may also be used to enable analytics (e.g. Google Analytics)

or advertising functionality (e.g., ad retargeting on third-party websites) that enables more

customized services and advertising by tracking your interaction with our Service and collecting

information about how you use the Service.

Flash cookies, which are cookies written using Adobe Flash, and which may be permanently

stored on your device. Like regular cookies, Flash cookies may help store user preferences and

activity, and may allow a website to recognize a particular browser or device. Flash cookies are

not managed by the same browser settings that are used for regular cookies.

Web beacons, which are pieces of code embedded in a website or email to monitor your activity

on the website or your opening of the email, and which can pass along information such as the

IP address of the computer or device you use to view the website or open the email, the URL

page on which the web beacon is located, the type of browser that was used to access the

website, and previously set cookie values. Web beacons are sometimes used to collect

advertising data, such as counting page views, promotion views or advertising responses.

Disabling your computer's, device's or browser's cookies may prevent some web beacons from

tracking or recording certain information about your activities.

Scripts, which are pieces of code embedded in a website to define how the website behaves in

response to certain key or click requests sent by the user. Scripts are sometimes used to collect

information about the user's interactions with the website, such as the links the user clicks on.

Scripts are often times temporarily downloaded to the user's computer or device from the

website server, active only while the user is connected to the Site and/or the App, and

deactivated or deleted when the user disconnects from the website.

Analytic tools and services, which are sometimes offered by third parties, and which track,

measure and/or generate information about a website's or program's traffic, sales, audience and

similar information, and which may be used for various reasons, such as, for example, statistical

research, marketing research, and content ratings research, and conversion tracking. Examples

of the analytic tools and services which “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” might use include Google Analytics and Taplytics. “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” may also use other third-party analytic tools and services.

Please be advised that if you choose to block, reject, disable, delete or change the management

settings for any or all of the aforementioned technologies and/or other tracking, data

aggregation and data analysis technologies, then certain areas of the Platform might not

function properly.

By visiting, accessing or using the Service, you acknowledge and agree in each instance that

you are giving “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” permission to monitor or otherwise track your activities on the Service, and that “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” may use the aforementioned technologies and/or other tracking, data aggregation and data analysis technologies. Notwithstanding the foregoing,

“EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” does not permit third parties or third-party cookies to access any communications you have with the Providers, or medical information that you submit to the

Providers for diagnosis and treatment purposes.

Use of Information

In connection with providing the Service, we and our affiliates and service providers may use

your information, subject to the limitations addressed in the Protected Health Information

Section above, for a number of purposes, including, but not limited to:

Verifying your identity;

Confirming your location;

Administering your account;

Fulfilling your requests;

Processing your payments;

Facilitating your movement through the Service;

Facilitating your use of the Service and/or products or services offered through the Service;

Communicating with you by letter, email, text, telephone or other forms of communication,

including on behalf of your Provider(s) to facilitate telehealth Services;

Providing you with information about “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC”, the Labs, the Pharmacies, the Medical Groups, the Providers and/or their businesses, products and services by letter, email,

text, telephone or other forms of communication;

Providing you with customer support;

Providing you with information about third-party businesses, products and services by letter,

email, text, telephone or other forms of communication;

Developing, testing or improving the Service and content, features and/or products or services

offered via the Service;

Identifying or creating new products, services, marketing and/or promotions for “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” or the Service; Promoting and marketing “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC”, the Service, and the products and/or services

offered via the Service; Improving user experiences with the Service;

Analyzing traffic to and through Service;

Analyzing user behavior and activity on or through the Service;

Conducting research and measurement activities for purposes of product and service research

and development, advertising claim substantiation, market research, and other activities related

to “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” , the Service or products and services offered via the Service; Monitoring the activities of you and others on or through the Service;

Placing and tracking orders for products or services on your behalf;

Protecting or enforcing “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC”’ rights and properties;

Protecting or enforcing the rights and properties of others (which may include you);

When required by applicable law, court order or other governmental authority (including, without

limitation and by way of example only, in response to a subpoena or other legal process); or

“EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” believes in good faith that such use is otherwise necessary or advisable (including, without limitation and by way of example only, to investigate, prevent, or take legal

action against someone who may be causing injury to, interfering with, or threatening the rights,

obligations or properties of “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC”, a user of the Service, which may include you, or anyone else who may be harmed by such activities or to further “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” legitimate business interests).

We may de-identify your information and use, create and sell such de-identified information, or

any business or other purpose not prohibited by applicable law.

Disclosure of Information

Subject to the limitations described in the Protected Health Information section above, we may

disclose your information to third parties in connection with the provision of our Service or as

otherwise permitted or required by law. For example, we may disclose your information to:

Our third-party and service providers (collectively "vendors") that provide services to enable us

to provide the Service, such as the hosting of the Service, data analysis, IT services and

infrastructure, customer service, email delivery, and other similar services;

Our vendors that provide services to enable us to run our business and administrative

operations, such as legal and financial advisory services, auditing services, analytics and similar

services;

Our vendors that provide services to enable us to promote and advertise the Service and the

products and/or services offered via the Service, such as ad platforms or ad-retargeting

services, as well as comply with contact removal requests or requirements, such as mailing list

removal services, do not call registries, and similar services;

The Labs, Pharmacies, Medical Group or its Providers to enable them to provide services to you

via the Service and to collect payment on their behalf;

Vendors as we believe necessary or appropriate to comply with applicable laws; and

To a third party in the event of any reorganization, merger, sale, joint venture, assignment,

transfer, liquidation or other disposition of all or any portion of our business, assets or stock with

such third party.

We may de-identify your information and disclose such de-identified information for any purpose

not prohibited by applicable law.

Data Retention

“EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC ” may retain your information for as long as it believes necessary; as long as necessary to comply with its legal obligations, resolve disputes and/or enforce its agreements;

and/or as long as needed to provide you with the products and/or services of the Service or

“EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC”. “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” may dispose of or delete any such information at anytime, except as set forth in any other agreement or document executed by “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” or as required by law.

Similarly, the Medical Groups and Providers may retain your information for as long as they

believe necessary; as long as necessary to comply with their respective legal obligations,

resolve disputes and/or enforce its agreements; and/or as long as needed to provide you with

the products and/or services of the Medical Groups and Providers. The Medical Groups and

Providers may dispose of or delete any such information at any time, except as set forth in any

other agreement or document executed by the Medical Groups or Providers or as required by

law.

Transactions

In connection with any transaction that you conduct through the Service (e.g., the purchase or

sale of any products or services on or through the Service), you may be asked to supply certain

information relevant to the transaction, including, without limitation, your credit card number and

expiration date, your billing address, your shipping address, your phone number and/or your

email address. By submitting such information, you grant “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” without charge the irrevocable, unencumbered, universe-wide and perpetual right to provide such information to

third parties (e.g., payment processing companies, buyers on the Service, sellers on the

Service) for the purpose of facilitating the transaction.

All credit card, debit card and other monetary transactions on or through the Service occur

through an online payment processing application(s) accessible through the Service. This online

payment processing application(s) is provided by “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” third-party online payment processing vendor, Stripe ("Stripe"). Additional information about Stripe, its privacy

policy and its information security measures (collectively, the " Stripe Policies'') should be

available on the Stripe website located at https://stripe.com/us/privacy or by contacting Stipe

directly. Reference is made to the Stripe Policies for informational purposes only and are in no

way incorporated into or made a part of this Privacy Policy. “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” relationship with Stripe, if any, is merely contractual in nature, as Stripe nothing more than a third-party

vendor to “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC”, and is in no way subject to “EMBODHI INTEGRATIVE WELLNESS AND MEDSPA LLC” direction or control; thus, their relationship is not, and should not be construed as, one of fiduciaries, franchisors-franchisees, agents-principals, employers-employees, partners, joint venturers or the like.

Jurisdictional Issues

The Service may only be used within certain states within the United States as described in our

Terms and Conditions. Accordingly, this Privacy Policy, and our collection, use, and disclosure of

your information, is governed by U.S. law.

Third Parties

This Privacy Policy does not address or apply to, and we are not responsible for, the privacy,

information or other practices of any third parties, including, without limitation, the Medical

Group or its Providers, the manufacturer of your mobile device, and any other third-party mobile

application or website to which our Service may contain a link. These third parties may at times

gather information from or about you. We do not control and are not responsible for the privacy

practices of these third parties. We encourage you to review the Medical Group's Notice of

Privacy Practices and the privacy policies of each website and application you visit and use.